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HomeMy WebLinkAbout10-0393FILED-OFFICE (DC TP- PPC ? ,j( TARP 2010 JAN 15 PM 3: 50 KRISTA K. KREBS, : IN THE COUR3 , Plaintiff : CUMBERLAND C LAN S a V. CIVIL ACTION - LAW 2010 - 3 ?3 CIVIL TERM RONALD WILLIAM BAER, Defendant IN CUSTODY COMPLAINT FOR CUSTODY .S OF VANIA AND NOW comes the Plaintiff, Krista K. Krebs, by her attorneys, Irwin & McKnight, P.C., and presents the following Complaint for Custody. 1. The Plaintiff, Krista K. Krebs, is an adult individual with an address of 71 Cold Spring Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, Ronald William Baer, is an adult individual with an address of 66 Encks Mill Road, Carlisle, Cumberland County, Pennsylvania 17015. 3. The parties are the natural parents of two (2) children, namely, Emma K. Baer, born August 11, 1997, and Ella G. Baer, born September 5, 2000. 4-0- 39i7 Alto a3G3/ob 4. The Plaintiff, Krista K. Krebs, desires that she have sole legal custody of the minor children, Emma K. Baer and Ella G. Baer. 5. The Plaintiff, Krista K. Krebs, desires sole physical custody of the said minor children with periods of supervised visitation to Defendant, Ronald William Baer, as the parties can agree. 6. The best interests and permanent welfare of the minor child requires that the Court grant the Plaintiff's request as set forth above. WHEREFORE, the Plaintiff, Krista K. Krebs, respectfully requests that she be awarded sole physical custody and sole legal custody of the minor children, Emma K. Baer and Ella G. Baer as provided herein, with periods of temporary physical custody to Defendant, Ronald William Baer, as provided herein. Respectfully submitted, IRWIN&McNI HT, P.C. K By: Mar .ight, I, Esquire Atto ey r Plaintiff 60 West P fret Street Carlisle, Penn 17013-3222 (717) 249-2353 Supreme Court I. D. No. 25476 Date: January 11, 2010 VERIFICATION The foregoing Complaint for Custody is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. A K. KRE S Date: January 11, 2010 KRISTA K. KREBS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ?_ 2010 - 5 9 3 CIVIL TERMr o -C' RONALD WILLIAM BAER ?- Defendant IN CUSTODY r a %un CUSTODY STIPULATION r 4 ^? + ^+ ry rn AND NOW, this-day of January, 2010, the parties, KRISTA K. IS awl RONALD WILLIAM BAER hereby enter into the following Custody Stipulation and Agreement regarding their minor children, EMMA K. BAER and ELLA G. BAER: 1. The Plaintiff, Krista K. Krebs, is an adult individual who resides at 71 Cold Springs Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, Ronald William Baer, is an adult individual who resides at 66 Encks Mills Road, Carlisle, Pennsylvania 17015. 3. The parties are the natural parents of two (2) children, namely, Emma K. Baer, born August 11, 1997, and Ella G. Baer, born September 5, 2000. 4. The parties agree that the Plaintiff, Krista K. Krebs, have sole legal custody of the minor children, Emma K. Baer and Ella G. Baer. 5. The Plaintiff/Mother shall have sole physical custody of the minor children, Emma K. Baer and Ella G. Baer. 2 6. The Defendant/Father shall have periods of supervised visitation at times as agreed upon by the parties. 7. The parties shall provide for supervised visitation of said minor children during all holidays pursuant to their best interest. 8. The parties shall keep each other advised immediately in the event of serious illness or medical emergency concerning the children, and shall take any necessary steps to ensure that the health and well-being of the children are protected. During such illness or medial emergency, both parties shall have the right to visit the children as often as he or she desires consistent with the proper medical care of the children. 9. The parties shall not do anything that may estrange the children from the other party, or injure the opinion of the children as to the other parry, or hamper the free and natural development of the children's love and affection for the other party. 10. The parties may make such alternate arrangements regarding the physical custody of the children so long as they may mutually agree. The parties anticipate regularly varying from the terms of this Stipulation in order to accommodate the schedules of each other and the children. However, if the parties cannot reach a mutual agreement, the terms of this Stipulation and Order shall control. 3 11. Any modification or waiver of any other provisions of this Agreement shall be effective only if made in writing and only if executed with the same formality as this Stipulation and Agreement. 12. The parties desire that this Stipulation and Agreement be made an Order of the Court of the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the issue of custody of the parties' minor child who has resided in Cumberland County for more than six months and shall retain such jurisdiction should circumstances change and either party desires or requires modification of said Order. 13. The parties acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable and that it is not the result of duress or undue influence. 14. Each party has had an opportunity to consult independent legal counsel of his or her own selection. Each party regards the terms of this Agreement as fair and equitable, and each has signed it freely and voluntarily without relying upon any representation other than those expressly set forth herein. 4 IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms set forth above, enter their hands and seals the date first set forth above. WITNESSETH: t ;- 6 c (SEAL) K 6& C "S TA K. KREBS 'v ?---' SEAL RONALD WILLIAM BAER . I 'J. 'JAN '9201j) KRISTA K. KREBS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2010-39 3 RONALD WILLIAM BAER, Defendant IN CUSTODY ORDER OF COURT CIVIL TERM `r' AND NOW, this day of aq big' 010, upon presentation and consideration of the attached Custody Stipulation and Agreement, it is hereby Ordered and Directed that it be entered as an Order of Court. -"-Ron William Baer ld Defendant Marcus A. McKnight, III, Esq. Attorney for Plaintiff (26c)1 E S m,;g t f 11a011d '-7-r>1 By the Court, n CC= -, C) I r 1 . L KRISTA K. KREBS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW d O a 2010 - 5 Y3 CIVIL TERMO RONALD WILLIAM BAER, C- '33 ?ij Defendant IN CUSTODY cn C: CUSTODY STIPULATION 4 r = w AND NOW, this-day of January, 2010, the parties, KRISTA K. KRS anal rm r RONALD WILLIAM BAER hereby enter into the following Custody Stipulation and Agreement regarding their minor children, EMMA K. BAER and ELLA G. BAER: 1. The Plaintiff, Krista K. Krebs, is an adult individual who resides at 71 Cold Springs Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, Ronald William Baer, is an adult individual who resides at 66 Encks Mills Road, Carlisle, Pennsylvania 17015. 3. The parties are the natural parents of two (2) children, namely, Emma K. Baer, born August 11, 1997, and Ella G. Baer, born September 5, 2000. 4. The parties agree that the Plaintiff, Krista K. Krebs, have sole legal custody of the minor children, Emma K. Baer and Ella G. Baer. 5. The Plaintiff/Mother shall have sole physical custody of the minor children, Emma K. Baer and Ella G. Baer. 2 J 6. The Defendant/Father shall have periods of supervised visitation at times as agreed upon by the parties. 7. The parties shall provide for supervised visitation of said minor children during all holidays pursuant to their best interest. 8. The parties shall keep each other advised immediately in the event of serious illness or medical emergency concerning the children, and shall take any necessary steps to ensure that the health and well-being of the children are protected. During such illness or medial emergency, both parties shall have the right to visit the children as often as he or she desires consistent with the proper medical care of the children. 9. The parties shall not do anything that may estrange the children from the other party, or injure the opinion of the children as to the other party, or hamper the free and natural development of the children's love and affection for the other party. 10. The parties may make such alternate arrangements regarding the physical custody of the children so long as they may mutually agree. The parties anticipate regularly varying from the terms of this Stipulation in order to accommodate the schedules of each other and the children. However, if the parties cannot reach a mutual agreement, the terms of this Stipulation and Order shall control. 11. Any modification or waiver of any other provisions of this Agreement shall be effective only if made in writing and only if executed with the same formality as this Stipulation and Agreement. 12. The parties desire that this Stipulation and Agreement be made an Order of the Court of the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the issue of custody of the parties' minor child who has resided in Cumberland County for more than six months and shall retain such jurisdiction should circumstances change and either party desires or requires modification of said Order. 13. The parties acknowledge that they have read and understand the provisions of this Agreement. Each party acknowledges that the Agreement is fair and equitable and that it is not the result of duress or undue influence. 14. Each party has had an opportunity to consult independent legal counsel of his or her own selection. Each party regards the terms of this Agreement as fair and equitable, and each has signed it freely and voluntarily without relying upon any representation other than those expressly set forth herein. 4 IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms set forth above, enter their hands and seals the date first set forth above. WITNESSETH: (SEAL) "S 'TA K. KREBS ? v--- (SEAL) RONALD WILLIAM BAER